ASA Adjudication on Camelot Group plc

Ad

An e-mail from the National Lottery, sent to customers who had an online account, said "xxxx [name of recipient], there are big jackpots to be won every week, so unless you've been abducted by aliens ... you'll need a very good excuse for not playing every week - need an excuse?". A paragraph titled “Don’t miss a chance to win” stated “The more you play the more likely you are to win. And when you play the Lotto online there’s plenty of opportunity to get in the draw. Give yourself even more of a chance by playing multiple lines at once, and playing for the Saturday and Wednesday draws”. At the bottom of the main body of the e-mail, text in a large font said "The National Lottery What's your excuse?". To the right of the main body of the e-mail there were two boxes of text, one of which said "Excuse you! Need the perfect excuse? Then have a go on the excuse generator! Get your excuses now!", and another which said "There's no excuse for not playing online. Play now!"

Issue

A recipient challenged whether the ad was irresponsible by:

1. implying that gambling was indispensible; and

2. encouraging excessive gambling.

CAP Code (Edition 11)

Response

Camelot Group plc (Camelot) said the ad was one of a series of e-mails which were sent to National Lottery players who had opted to receive marketing communications.  They said that the purpose of the campaign was to encourage recipients, in a lighthearted way, to consider playing the lottery through their interactive channels.  They also said the ads contained a link to the "Excuse Generator", which created random lighthearted excuses such as "Im sorry Im late for work.  I was practising my lassoing and I got a bit tied up".  Camelot explained that none of these "excuses" were linked to the Lottery or to gambling.   

1. They said the ad did not imply that gambling was indispensible and reasoned that it merely suggested that, because of the advantages of playing the Lottery interactively, a good excuse was needed by recipients if they were to miss out.  

2. They said the ad was designed to stress some of the advantages of playing the Lottery interactively and mentioned features like automated ticket checking, advance play and win notifications.  They said the ad did not encourage excessive play but provided information that helped recipients decide if they wanted to play Lottery games interactively.

Assessment

1. Not upheld.

The ASA considered that, although the ad suggested recipients should have a good "excuse" not to play the Lottery, it did so in a lighthearted and humorous way.  We considered that the ad did not suggest there would be serious consequences from not playing, or that playing the Lottery should be a priority. We concluded that recipients were unlikely to infer from the ad that gambling was indispensible.

On this point, we investigated the ad under CAP Code clause 2.2 (Social responsibility) but did not find it in breach.

2. Upheld

We considered that the ad focused on the benefits of playing the Lottery interactively and invited recipients to use their interactive account repeatedly by stating "The more you play the more likely you are to win".  We noted the ad suggested that recipients had a higher chance of winning if they bought multiple lines, across the numerous Lottery games on both the Wednesday and Saturday weekly draws, and concluded that, by referring to the greater chance of winning resulting from multiple entries, the ad encouraged repeated and potentially excessive gambling.

On this point the ad breached CAP Code clause 2.2 (Social responsibility).

Action

The ad should not appear again in its current form.

Adjudication of the ASA Council (Non-broadcast)